``The allegations against Gary Payton are completely without merit ... ,'' the statement said. ``Gary will take whatever action is necessary to protect his personal and professional reputation, including pursuing any and all actions he may have against the parties who have intentionally misrepresented the truth at Gary's expense.''

Shala, a driver from A Hollywood Dream Limousines in suburban Brookfield, was assigned to Payton both Sunday and Monday night. Although he filed a battery complaint, police say he did not sign a summons that would have forced Payton to go to criminal court.